NCGNE0013_COMPLETE FILE - HISTORICAL_20081023

STORMWATER DIVISION CODING SHEET
RESCISSIONS
PERMIT NO.
Al�
DOC TYPE
❑COMPLETE FILE -HISTORICAL
DATE OF
RESCISSION
❑ oZda l lD c-)--3
YYYYMMDD

EGY7
NCDEjR
North Carolina Department of Environment and
Division of Water Quality
Beveriy Eaves Perdue Coleen H. Sullins
Governor Director
March 13, 2009
Stuart Hurwitz, P.E., CHMM
IBM Research Triangle Park
P.O. Box 12195, 2031DI07B
Research Triangle Park, NC 27709 '
Natural Resources
Subject: No -Exposure Certification Rescission
No -Exposure Certification NCGNE0013
IBM (RTP, NC)
Durham County
Dear Mr. Hurwitz:
Dee Freeman
Secretary
The Division has reviewed your request for rescission of the No -Exposure Certification for the above
site, sent to us on October 23, 2008. Because IBM Research Triangle Park is no longer a hazardous waste
treatment, storage, or disposal facility, the Division is granting your rescission request. Therefore, your
coverage under No -Exposure Certification NCGNEOO13 is hereby rescinded.
Based on our evaluation, the Division agrees with IBM's determination that the facility no longer requires
the conditional no -exposure exclusion under 40 CFR 122.26(g). However, should conditions change such
that this facility's industrial activities are subject to NPDES stormwater regulations, you are obligated to
immediately obtain NPDES permit coverage for your stormwater discharges or to apply for a No
1xposure exclusion (if eligible). Otherwise, any discharge becomes subject to enforcement as an utl-
permitted discharge.
This rescission does not affect your facility's legal requirements to obtain environmental permits that may
be required tinder other federal, state, or local regulations or ordinances. If you have any questions or
need further information, please contact Bethany Georgoulias at [phone], or at
bcthany.georgoulias cr ncmail.net.
Sincerely,
for Coleen H. uilim
cc: Raleigh Regional Office
Stormwater Permitting Unit No Exposure Files (NCGNEOO13)
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27599-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-5748
Internet: www.newaterquality.org
Nne
oaliCar.olina
Aittwally
An Equal Opportunity lAtrrmativeAction Employer

Imemational Business Machines Corporation Stuarl A. 1luneilz, Y.li.('rX), CHWt
P.O. Box 12195. 2031 D 107 B
Research Triangle Park, NC 27709
(919)254-OR10
[phone] fas
October 23, 2008
Bethany Georgoul;as
NCDENR Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Applicability of NI'DES Storm Water Regulations K Request to Rescind
No EXposure Certilication
Reference: No Exposure Certification. I13M-10f11. Durham Comity.
1)WQ Tracking No. NCGNE0013
Dear Ms. Georgoulias:
I Want to thank you and Mr. Randall for speaking with me on October 13, 2008 regarding the
continued applicability ofthe National Pollutant Discharge Elimination System (NPDES)
stormwater regulations to the I13M Research Triangle Park facility, As we discussed, the II3M
RTP site is currently covered under No I]xposure Certification NCGNE0013 issued April 28,
2004.
An evaluation ol'the current facility indicates that we no longer meet any of the categories
considered to be engaging in "industrial activity" defined in 40 CFR 122.26(b)(14). In
particular, our NAILS Code 5415191 SIC Code 7379 is not within those specified in the
definitions. In addition, effective 1 1/24/04, IBM Research Triangle Park completed RCRA
closure of our hazardous waste storage facility, therefore I13M WIT is no longer a "Hazardous
waste treatment, storage, or disposal facility." However, we do maintain a Hazardous and Solid
Waste Amendments (HWSA) permit solely for the purposes of'groundwater corrective action.
We were planning to submit a reneW3! of -our certification by October 28. 2008, however, since
113M Research Triangle Park no longer falls within the applicable del inition of having a storm
water discharge associated with industrial activity. the requirement for NPD11S storm water
permitting is no longer necessary and we respectfully request that the referenced No Exposure
Certification be rescinded.
mo
Please contact me at 919-254-0810 ifyou have any questions.
m
o
n
m
S;ncer lv'at1
Stuart Hurwitz, PE (TX), CI-IMM
oo
cc: Kermit Smith, Manager, IBM RTI' f-acilitics Engineering and Design

inlcrnuliuu;il BLISIINS5 Nfildl1IIC5 Corparatiun
October 23, 2008
Be4hany 6corgoulias
NCDENR Division of Water Quality
Stormwatcr Permitting Unit
1617 Mail SCI'VSCe Centel -
Raleigh. NC 27699-1617
Stuorl A. I lurwit7.. P.L(T\). C'S NIM.
P.O. Igo\, 12195. 210ID107B
Itusc,irch Triangle Puk. NC 277011
[9191 254-081II
(919) 5•13-9617 11n
Subject: Applicability oI'NPDES StorIll 1'`,f ltcr Regillationti &RQCILICst to IZCSclI)d
No ) Xposmv Certification
Reference: No Exposure Certification. [BM-10T. DUrht111 County.
DWQ Tracking No. NCGNE-0013
Dear Ms. Georgoulias:
1 want to thank you and Mr. Randall for speaking with me on QCLObCI' t i, 2009 regarding the
continued applicability of the National Pollutant Discharge 111imination System (NPDI-S)
stormwater regulations to the IBM Research Triangle Park facility. As we discussed, the IBM
RTP site is currently covered under No EXposur'e Certification NCGNE0013 issued April 28.
2004.
An evaluation of the: current facility indicates that we no longer meet any of the categories
considered to be engaging in "industrial activity" defined in 40 CFR I22.2G(h)(14), In
particular, our NAICS Code 541519 1 SIC Code 7379 is not ,vithin those specified in the
definitions. In addition, effective 1 1 /24/04, 113M Research Triangle Park completed RCRA
closUl'c of our hitZal-CIOUS waste storage facility, therefore UM RTl' is no Ionger a "l-Iazardnus
waste treatIllent. storage, or Cllsposal facility." However, we do maintain a Hazardous and Solid
Waste Amendments (1-fWSA) permit solely for the purposes of'g,ruundwater corrective action.
We were planning to sublllit a renewal of our certification by October 28. 2008, however, since
113M.Research Triangle Park no longer- falls within the applicahle definition of having a storm
water discharge associated with indusu'lal activity, the requirement for NPDI=.S storm water
permitting is no longer neccssary and we respectfully rcquetit that tht. referenced No f Aposurc
Certification be rescinded.
Please contact me at 919-254-OS10 if yotl have any questions.
Si
Stuart Hurwitz, PE (TX), CHMM
cc: Kermit Smith, Manager. IBM R"TP Facilities Engineering and Design

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Rc: I13M�R.'U' NO Exposure Certification
A --
Subject: Re: 113M R'I'P No Exposure Certification
FI-01111: Stuart Hurwitz <hurwitZ a uS.Ibm.com>
Date: Thu, 12 Feb 2009 15:17:39 -0500
"I'o: Bethany Georgoulias <13ethany.Georgouhas a ncnlail.net>
CC: Mike Randall <mjkc.raiidall a ncnlail.iict>
Bethany, thanks for the status update.
As we've discussed, the RTP site is no longer a permitted treatment, storage, or disposal facility, however we do
have a permit to document our corrective action activities. This is primarily related to releases of chlorinated
solvents from former underground storage tanks in the late 1970's. The tanks have long since been removed.
We currently operate a groundwater treatment system where we pump from several groundwater wellslsumps
with the water being treated in an air stripper. The treated wastewater is discharged to the local POTW (Durham
County Wastewater Treatment Plant) under our industrial use discharge permit.
Please let me know if you have any other questions.
Regards,
Stuart Hurwitz
INTERNET: [e-mail]
Advisory Environmental Engineer, CHMM, PE (TX)
IBM RTP Facilities Engineering and Design, 2031 D107B, RTP, NC 27709
919-254-0810 (T/L 444), 919-737-6488 Digital Pager, Fax [phone] (TIL 441)
From:
Bethany Georgoulias <Bethany Georg oulias@ncmaiI nets
To:
Stuart Hurwitz/Raleigh/IBM@IBMUS
Cc:
Mike Randall <mike.randaII@ncmai1,net>
Date:
02/12/2009 03:01 PM
Subject:
Re: IBM RTP No Exposure Certification
hi Stuart,
Just wanted to send a note your way to let you know that we've been
trying to get in touch with EPA about IBM's requested rescission of the
No Exposure based on NPDES rules not being applicable, we haven't had
much luck so far, but hopefully we'll hear back from Region IV before
too long. In the event we don't, DWQ will ultimately have to make a
decision on our own.
r know we talked a long time ago about the circumstances, but could you
refresh us on the reason why the groundwater corrective action permit
was needed? (My notes from our conversation just say that it's being
pumped to an air stripper and then on to a POTW}. was it contamination
from previous TSD practices, IBM manufacturing practices, or prior
owners of the facility? This will be helpful to have on hand should the
question came up.
Thanks,
Bethany Georgoulias
5ethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
I of") 2/12/2009 3:20 PNI

Re: IBM RTP No EXposure Certification
1617 Mail Service Center, Raleigh, NO 27699-1617
512 N. Salisbury St, Raleigh, NO 27604
Phone: [phone]
Fax: [phone]
Website: htt2://h2o.enr. taLe.nc.us/su
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
Stuart Hurwitz wrote:
> Bethany, here is a copy of the submitted letter. FYI... I have a
> return receipt confirmation stamped by the mail service center on
> 10/27/08... of course, that doesn't mean the letter got to you.
> Please let me know if you have any questions.
> Regards,
> Stuart Hurwitz
> INTERNET: [e-mail]
> ---
> Advisory Environmental Engineer, CHMM, PE (TX)
> IBM RTP Facilities Engineering and Design, 20310107B, RIP, NC 27709
> 919-254-0810 (T/L 444), 919-737-6488 Digital Pager, Fax [phone]
> (T/L 441)
> From: Bethany Geor.goulias<[e-mail]>
> To: Mike Randall <[e-mail]>
> Cc: Stuart Hurwitz/Raleigh/IBM@IBMUS, Sarah Young
> <[e-mail]>, Bradley Bennett <[e-mail]>
> Date: 01/12/2009 09:29 AM
> Subject: Re: IBM RTP No Exposure Certification
> ------------------------------------------------------------------------
> Mike or Sarah,
> Did you ever see a letter come in from IBM related to their request for
> a rescission of their No Exposure? Sarah, did this maybe go to you or
> get forwarded to the regional office?
> Stuart just called and said they sent a letter to us back in October,
> but I don't think I ever saw it.
> Thanks,
> BG
> Bethany Gecrgoulias wrote:
> > Stuart,
> > I think this request sounds reasonable and includes a summary of the
> > relevant information we would need to know. Go ahead and send a
> > letter, and we'll consider the request based on our conversation
> > yesterday.
> > Regards,
> > Bethany Georgoulias
> > Stuart Hurwitz wrote:
> >> Bethany, I appreciate the call from you and Mike regarding our
> >> certification renewal. Please review the following -to confirm that I
> >> haven't mis-stated anything from our call.
> >> -------------
> >> As we discussed, the IBM RTP site is currently covered under No
> >> Exposure Certification MCGNE0013 issued April 28, 2004.
2 of 3 2 132N9 3:20 PM

RL:: 113M RT1No EXI)OsurC Certification
t
> >> An evaluation of the current facility indicates that we no longer
> >> meet any of the categories considered to be engaging in "industrial
> >> activity" defined in 40 CFR 122.26(b)(14). In particular, our NAICS
> >> Code 541519 / SIC Code 7379 is not within those specified in the
> >> definitions. In addition, effective 11/24/04, IBM Research Triangle
> >> Park completed RCRA closure of our hazardous waste storage Facility,
> >> therefore IBM RTP is no longer a "Hazardous waste treatment, storage,
> >> or disposal facility." However, we do maintain a Hazardous and Solid
> >> Waste Amendments (HWSA) permit solely for the purposes of groundwater
> >> corrective action.
> >> We were planning to submit a renewal of our certification by October
> >> 28, 2008, however, since IBM Research Triangle Park no longer falls
> >> within the applicable definition of having a storm water discharge
> >> associated with industrial activity, we request that the referenced
> >> No Exposure Certification be rescinded.
> >> -------------
> >> Regards,
> >> Stuart Hurwitz
> >> TWERNEV hurwi zks.ibm.com
> >> ---
> >> Advisory Environmental Engineer, CHMM, PE (TX)
> >> IBM RTP Facilities Engineering and Design, 2031D107B, RTP, NC 27709
> >> 919-254-0810 (T/L 444), 919-137-6488 Digital Pager, Fax [phone]
> >> (T/L 441)
> Bethany Georgoulias
> Environmental Engineer
> NC DENR Division of water Quality
> Stormwater Permitting Unit
> tel. [phone]
> fax [phone]
>
3 of 3 2M T2Of)9 3:2U PM